DETAILED ACTION
Notice of Pre-AIA or AIA Status
The present application, filed on or after March 16, 2013, is being examined under the first inventor to file provisions of the AIA .
This Office Action is in response to Request for Continued Examination filed on December 18, 2025.
Claims 21-40 are pending.
Claims 21, 28 and 35 have been amended.
Response to Amendment
Claim Rejections - 35 USC § 112
The following is a quotation of the first paragraph of 35 U.S.C. 112(a):
(a) IN GENERAL.—The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor or joint inventor of carrying out the invention.
The following is a quotation of the first paragraph of pre-AIA 35 U.S.C. 112:
The specification shall contain a written description of the invention, and of the manner and process of making and using it, in such full, clear, concise, and exact terms as to enable any person skilled in the art to which it pertains, or with which it is most nearly connected, to make and use the same, and shall set forth the best mode contemplated by the inventor of carrying out his invention.
Claims 21-40 are rejected under 35 U.S.C. 112(a) or 35 U.S.C. 112 (pre-AIA ), first paragraph, as failing to comply with the written description requirement. The claim(s) contains subject matter which was not described in the specification in such a way as to reasonably convey to one skilled in the relevant art that the inventor or a joint inventor, or for applications subject to pre-AIA 35 U.S.C. 112, the inventor(s), at the time the application was filed, had possession of the claimed invention. Independent claims 21, 28 and 35 state that the “applying the first feature treatment… without redeployment of the configurable application”. The Examiner has looked through the specification and has not found support for “without redeployment of the configurable application”. In the Remarks, Applicant cites Paragraphs 4, 21-22 and 34 has possible locations for support for the claim language. However, after reading these paragraphs, the Examiner does not see explicit support or use of the terms “without redeployment”. The Paragraphs appear to discuss “applying the first feature treatment” in “real time” but that does not necessarily mean that “redeployment” is not performed.
Claim Rejections - 35 USC § 101
35 U.S.C. 101 reads as follows:
Whoever invents or discovers any new and useful process, machine, manufacture, or composition of matter, or any new and useful improvement thereof, may obtain a patent therefor, subject to the conditions and requirements of this title.
Claims 21-40 are rejected under 35 U.S.C. 101 because the claimed invention recites a judicial exception, is directed to that judicial exception, an abstract idea, as it has not been integrated into practical application and the claims further do not recite significantly more than the judicial exception. Examiner has evaluated the claims under the framework provided in the 2019 Patent Eligibility Guidance published in the Federal Register 01/07/2019 and has provided such analysis below.
Step 1: Claims 21-27 are directed to methods and fall within the statutory category of processes; Claims 28-34 are directed to a system and fall within the statutory category of machines; and Claims 35-40 are directed to a non-transitory computer readable medium and fall within the statutory category of articles of manufacture. Therefore, “Are the claims to a process, machine, manufacture or composition of matter?” Yes.
In order to evaluate the Step 2A inquiry “Is the claim directed to a law of nature, a natural phenomenon or an abstract idea?” we must determine, at Step 2A Prong 1, whether the claim recites a law of nature, a natural phenomenon or an abstract idea and further whether the claim recites additional elements that integrate the judicial exception into a practical application.
Step 2A Prong 1:
Claims 21, 28 and 35: The limitation “attributing an event, associated with the event tracking message, to the first feature treatment, based on the first system identifier, the second system identifier, and the timestamp”, as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think and observe, judge and evaluate an event tracking message and mentally attribute, with or without the use of pen and paper, an event, associated with the event tracking message, to a first feature treatment, based on a first system identifier, a second system identifier, and a timestamp.
Therefore, Yes, claims 21, 28 and 35 recite judicial exceptions.
The claims have been identified to recite judicial exceptions, Step 2A Prong 2 will evaluate whether the claims are directed to the judicial exception.
Step 2A Prong 2:
Claims 21, 28 and 35: The judicial exception is not integrated into a practical application. In particular, the claim recites the following additional elements – “a server computer system”, “a memory; and a processing device, operatively coupled to the memory, the processing device configure to:…”, “A non-transitory computer-readable medium, having instructions stored thereon which, when executed by a processing device, cause the processing device to perform operations…” and “applying the first feature treatment, specified by the second system, that satisfies the first rule and identifies the first system to selectively change a first feature of the configurable application executing on the first system in real time and without redeployment of the configurable application” which are merely recitations of generic computing components and functions being used as a tool to apply the abstract idea (see MPEP § 2106.05(f)) which does not integrate a judicial exception into practical application. Further, claims 21, 28 and 35 recite the following additional elements – “receiving, by a server computer system, an event tracking message associated with a first system, wherein the event tracking message is transmitted from a software development kit (SDK) or an application programming interface (API) of the first system” and “receiving a first rule, specified by the second system, including the second system identifier” which are merely recitations of insignificant data gathering activity (see MPEP § 2106.05(g)) which does not integrate a judicial exception into practical application and will also be addressed below in Step 2B as also being Well-Understood, Routine and Conventional. Further still, claims 21, 28 and 35 recite the following additional elements – “the event tracking message including: a first system identifier that identifies the first system, a second system identifier that identifies a second system, and a timestamp”, “the first rule: identifying the first system, and defining how the first system is identified during an experiment, the experiment applying a first feature treatment to a configurable application executing on the first system” and “the timestamp indicating that the event occurred at a time after: a start time of the experiment, a first buffer period of time before the first rule identifies the first system, and application of the first feature treatment to the configurable application” which are merely recitations of field of use/technological environment (see MPEP § 2106.05(h)) which does not integrate a judicial exception into a practical application.
Therefore, “Do the claims recite additional elements that integrate the judicial exception into a practical application? No, these additional elements do not integrate the abstract idea into a practical application and they do not impose any meaningful limits on practicing the abstract idea. The claim is directed to an abstract idea.
After having evaluating the inquires set forth in Steps 2A Prong 1 and 2, it has been concluded that claims 21, 28 and 35 not only recite a judicial exception but that the claims are directed to the judicial exception as the judicial exception has not been integrated into a practical application.
Step 2B:
Claims 21, 28 and 35: The claims do not include additional elements, alone or in combination, that are sufficient to amount to significantly more than the judicial exception. As discussed above with respect to integration of the abstract idea into a practical application, the additional elements amount to no more than generic computing components, mere instructions to apply an exception and field of use/technological environment which do not amount to significantly more than the abstract idea. Moreover, the recitations of insignificant data gathering activity as also Well-Understood, Routine and Conventional. See at least MPEP § 2106.05(d)(II) “The courts have recognized the following computer functions as well‐understood, routine, and conventional functions when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity. i. Receiving or transmitting data over a network, e.g., using the Internet to gather data”. That is, in the instant claims these limitations merely receive or transmit/provide data which is Well-Understood, Routine and Conventional.
Therefore, “Do the claims recite additional elements that amount to significantly more than the judicial exception? No, these additional elements, alone or in combination, do not amount to significantly more than the judicial exception.
Having concluded analysis within the provided framework, Claims 21, 28 and 35 do not recite patent eligible subject matter under 35 U.S.C. § 101.
With regard to claims 22, 29 and 36, they recite additional element of “wherein the timestamp further indicates that the event occurred at a time before a second buffer period of time after an end time of the experiment” which is merely a recitation of field of use/technological environment (see MPEP § 2106.05(h)) which does not integrate a judicial exception into a practical application and does not amount to significantly more. Further, claims 22, 29 and 36 do not recite any further additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claims 22, 29 and 36 also fails both Step 2A prong 2, thus the claims are directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more. Therefore, claims 22, 29 and 36 do not recite patent eligible subject matter under 35 U.S.C. § 101.
With regard to claims 23, 30 and 37, they recite additional element of “receiving a second rule, specified by the second system, including the second system identifier” which is merely an insignificant data gathering activity (see MPEP § 2106.05(g)) which does not integrate a judicial exception into practical application and is also Well-Understood, Routine and Conventional. See at least MPEP § 2106.05(d)(II) “The courts have recognized the following computer functions as well‐understood, routine, and conventional functions when they are claimed in a merely generic manner (e.g., at a high level of generality) or as insignificant extra-solution activity. i. Receiving or transmitting data over a network, e.g., using the Internet to gather data”. That is, in the instant claims these limitations merely receive or transmit/provide data which is Well-Understood, Routine and Conventional. Further, claims 23, 30 and 37 recite additional element of “applying the second feature treatment, specified by the second system, to the configurable application executing on the first system” which is merely a recitation of generic computing components and functions being used as a tool to apply the abstract idea (see MPEP § 2106.05(f)) which does not integrate a judicial exception into practical application and does not amount to significantly more. Further still, claims 23, 30 and 37 recite additional element of “the second rule: identifying the first system, and defining how the first system is identified during the experiment, the experiment applying a second feature treatment to the configurable application executing on the first system”, “the second feature treatment: satisfying the second rule identifying the first system, and configuring a second feature of the configurable application” and “wherein the timestamp further indicates that the event occurred at a time after the application of the second feature treatment to the configurable application” which are merely recitations of field of use/technological environment (see MPEP § 2106.05(h)) which does not integrate a judicial exception into a practical application and do not amount to significantly more. Further, claims 23, 30 and 37 do not recite any further additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more claims 23, 30 and 37 also fails both Step 2A prong 2, thus the claims are directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more. Therefore, claims 23, 30 and 37 do not recite patent eligible subject matter under 35 U.S.C. § 101.
With regard to claims 24, 31 and 38, they recite additional abstract idea recitations of “excluding the event tracking message from attribution to the first feature treatment, in response to determining that, during the experiment, the event tracking message was received after application of a second feature treatment to the configurable application, the second feature treatment not satisfying the first rule” as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think about and observe, judge and evaluate an event tracking message, just as in the independent claims above, mentally exclude, with or without the use of pen and paper, the event tracking message from attribution to the first feature treatment, in response to determining that, during the experiment, the event tracking message was received after application of a second feature treatment to the configurable application, the second feature treatment not satisfying the first rule. Further, claims 24, 31 and 38 do not recite any further additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claims 24, 31 and 38 also fails both Step 2A prong 2, thus the claims are directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more. Therefore, claims 24, 31 and 38 do not recite patent eligible subject matter under 35 U.S.C. § 101.
With regard to claims 25, 32 and 39, they recite additional abstract idea recitations of “excluding the event tracking message from attribution to the first feature treatment, in response to determining that, during the experiment, the event tracking message was received after a change to the first rule was applied to the configurable application, the first feature treatment not satisfying the change to the first rule” as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think about and observe, judge and evaluate an event tracking message, just as in the independent claims above, mentally exclude, with or without the use of pen and paper, the event tracking message from attribution to the first feature treatment, in response to determining that, during the experiment, the event tracking message was received after a change to the first rule was applied to the configurable application, the first feature treatment not satisfying the change to the first rule. Further, claims 25, 32 and 39 do not recite any further additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claims 25, 32 and 39 also fails both Step 2A prong 2, thus the claims are directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more. Therefore, claims 25, 32 and 39 do not recite patent eligible subject matter under 35 U.S.C. § 101.
With regard to claims 26, 33 and 40, they recite additional abstract idea recitations of “assigning a first feature version to the first feature treatment” as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think about and observe, judge and evaluate a first feature treatment, just as in the independent claims above, mentally assign, with or without the use of pen and paper, a first feature version to the first feature treatment. Further, claims 26, 33 and 40 recite additional abstract idea recitations of “assigning a second feature version to the first feature treatment” as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think about and observe, judge and evaluate a first feature treatment, just as in the independent claims above, mentally assign, with or without the use of pen and paper, a second feature version to the first feature treatment. Further still, claims 26, 33 and 40 recite additional abstract idea recitations of “analyzing a sample set of events associated with at least one of the first feature version or the second feature version” as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think about and observe, judge and evaluate a sample set of events, just as in the independent claims above, mentally analyze, with or without the use of pen and paper, the sample set of events associated with at least one of the first feature version or the second feature version. Further still, claims 26, 33 and 40 recite additional element of “in response to deploying a new version of the configurable application” which is merely a recitation of generic computing components and functions being used as a tool to apply the abstract idea (see MPEP § 2106.05(f)) which does not integrate a judicial exception into practical application and does not amount to significantly more. Further still, claims 26, 33 and 40 do not recite any further additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more, claims 26, 33 and 40 also fails both Step 2A prong 2, thus the claims are directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more. Therefore, claims 26, 33 and 40 do not recite patent eligible subject matter under 35 U.S.C. § 101.
With regard to claims 27 and 34, they recite additional element of “wherein the event tracking message is generated on a second system other than the first system” which is merely a recitation of generic computing components and functions being used as a tool to apply the abstract idea (see MPEP § 2106.05(f)) which does not integrate a judicial exception into practical application and does not amount to significantly more. Further, claims 27 and 34 do not recite any further additional elements and for the same reasons as above with regard to integration into practical application and whether additional elements amount to significantly more claims 27 and 34 also fails both Step 2A prong 2, thus the claims are directed to the judicial exception as it has not been integrated into practical application, and fails Step 2B as not amounting to significantly more. Therefore, claims 27 and 34 do not recite patent eligible subject matter under 35 U.S.C. § 101.
Therefore, Claims 21-40 do not recite patent eligible subject matter under 35 U.S.C. §101.
Response to Arguments
Applicant’s arguments, see Page 9, filed December 18, 2025, with respect to Double Patenting rejection of claims 21, 28 and 35 have been fully considered and are persuasive. The Double Patenting rejection of claims 21, 28 and 35 has been withdrawn.
Applicant's arguments filed December 18, 2025 have been fully considered but they are not persuasive.
In the Remarks, Applicant argues:
Additionally, without acquiescing to the rationale of the rejection and merely to
expedite the prosecution of the instant application, Claims 21, 28, and 35 have been
amended to further clarify integration into practical application and to further clarify that
the recited claimed features add significantly more.
More specifically, Claim 21 has been amended to recite that applying the first
feature treatment in real time and without redeployment of the configurable application, as claimed, to further clarify and more explicitly recite the patent eligible subject matter. As such, the recited claimed features improve the technology.
In other words, selectively changing a feature of the configurable application
executing on the first system allows the application being executed to be modified in
"real time" without requiring a redeployment. As such, the recited claimed features
improve the computer related technology and is integrated into a practical application.
Examiner’s Response:
The Examiner respectfully disagrees. It is the Examiner’s position that the newly amended claim language does not recited an improvement to computer related technology and thus, does not integrate the judicial exception into a practical application under Step 2A, Prong 2. As can be seen in the updated §101 rejection to claims 21, 28 and 35 above, the claim limitation of “applying the first feature treatment… in real time and without redeployment of the configurable application” has been analyzed under Step 2A, Prong 2 as being an additional element. However, this additional element is merely a recitation of generic computing components and functions being used as a tool to apply the abstract idea (see MPEP § 2106.05(f)) which does not integrate a judicial exception into practical application and thus cannot be the basis for the improvement to computer related technology.
Further, it is not clear from the current claim language of how “without redeployment of the configurable application” is advantageously achieved. The Applicant appears to claim a “result” (i.e. without redeployment) but fails to recite a description of the mechanism for accomplishing the result (see MPEP § 2106.05(f)). Thus, the judicial exception has not been integrated into a practical application because this type of recitation is equivalent to the words "apply it".
Therefore, for at least the reasons set forth above, the rejection made under 35 U.S.C. §101 is proper and thus, maintained.
In the Remarks, Applicant argues:
Furthermore, in the August 4, 2025 Memorandum the USPTO guidance on § 101
rejections further indicates that the courts consider a mental process (thinking) that "can be performed in the human mind, or by a human using a pen and paper" to be an abstract idea but further emphasizes and instructs examiners "to determine that a claim recite a mental process when it contains limitation(s) that can practically be performed in the human mind". In the August 4, 2025, Memorandum the USPTO guidance on § 101 rejections, the USPTO clarifies that the "mental process grouping is not without limits" and that the examiners "are reminded not to expand this grouping in a manner that encompasses claim limitations that cannot practically be performed in the human mind". Claim 1, as described above, is not directed to a mental process and is not abstract for reasons provided above in addition to being inextricably tied and necessarily rooted in the computer technology. Additionally, the recited claimed features
cannot be practically performed in the human mind.
In the instant application, the recited claimed features cannot practically be performed in an event tracking message associated with a configurable
the human mind, e.g., receiving… an event tracking message associated with a configurable application executing on a first system… transmitted from a software development kit (SDK) or an application programming interface (API)… [and] including: a first system identifier that identifies the first system, a second system identifier that identifies a second system, and a timestamp, receiving a first rule…identifying the first system… and defining how the first system is identified during an experiment, the experiment applying a first feature treatment to the configurable application executing on the first system, applying the first feature treatment… that satisfies the first rule and identifies the first system to selectively change a first feature of the configurable application executing on the first system in real time and without redeployment of the configurable application, attributing an event… to the first feature treatment based on the first system identifier/the second system identifier/the timestamp where the timestamp indicates that the event occurred at a time after: a start time of the experiment, a first buffer period of time before the first rule identifies the first system, and application of the first feature treatment to the configurable application, etc. As such, Claim 21 is not directed to a mental process and cannot be performed by pen/paper.
Examiner’s Response:
The Examiner respectfully disagrees. As can be seen in the updated §101 rejection above. The Examiner has not analyzed the “receiving… an event tracking message”, “receiving a first rule…” and “applying the first feature treatment…” under Step 2A, Prong 1 as being part of the mental process. These limitations were analyzed under Step 2A, Prong 2 and Step 2B as being additional elements. The claim limitation of “attributing an event…” was analyzed under Step 2A, Prong 1 as being part of the mental process. Specifically, the limitation “attributing an event, associated with the event tracking message, to the first feature treatment, based on the first system identifier, the second system identifier, and the timestamp”, as drafted, is a process that, but for the recitation of generic computing components, under its broadest reasonable interpretation, covers performance of the limitation in the mind. For example, a person can think and observe, judge and evaluate an event tracking message and mentally attribute, with or without the use of pen and paper, an event, associated with the event tracking message, to a first feature treatment, based on a first system identifier, a second system identifier, and a timestamp.
Therefore, claim 21 recites a claim limitation that is directed to a mental process.
In the Remarks, Applicant argues:
Additionally, in the August 4, 2025, Memorandum the USPTO guidance on § 101
rejections further emphasizes a stricter "preponderance of evidence" standard (more likely than not) for Examiners urging them to focus on technical improvements, not just abstract ideas, and to avoid mental process rejections for complex functions. Specifically, the Memorandum requires that Examiners must have more than 50% certainty (preponderance of evidence) to issue a § 101 rejection; uncertainty is not enough. Examiners should be wary of rejecting complex AI/ML steps as mental processes if they exceed human capability (e.g., neural network training) and valuate all claim elements, especially dependent claims, to see how they work together to
form a practical application.
Examiner’s Response:
As can be seen in the updated §101 rejection above, the Examiner has evaluated all claim elements, individually and as a whole, under Steps 2A, Prong 1 and 2 and Step 2B. It has been concluded that the claims are directed to a judicial exception and do not include any additional elements that integrate the judicial exception into a practical application and/or amount to significantly more.
In the Remarks, Applicant argues:
Furthermore, in the August 4, 2025, Memorandum the USPTO guidance on § 101 rejections, the Office indicates that "another consideration when determining whether a claim integrates a judicial exception into a practical application in Step 2A Prong Two is whether the additional elements amount to more than a recitation of the word 'apply it' (or an equivalent) or mere instructions to implement an abstract idea or other exception on a computer". The Office cautioned the Examiners from "oversimplify[ing]" claim limitations and from "expand[ing]" the application of "apply it" consideration. In the August 4, 2025, Memorandum the USPTO guidance on § 101 rejections, the Office provided further guidance for the Examiners to consider:
1. Whether the claim recites only the idea of a solution or outcome, i.e., the claim
fails to recite details of how a solution to a problem is accomplished, or the claim covers
a particular solution to a problem or a particular way to achieve a desired outcome.
2. Whether the claim invokes computers or other machinery merely as a tool to
perform an existing process, or whether the claim purports to improve computer
capabilities or to improve an existing technology.
3. The particularity or generality of the application of the judicial exception.
As described in the response filed on August 18, 2025, and further based on the
arguments provided above, Claim 21 recites details of how a solution to a problem is
accomplished. Moreover, Claim 21 recites features that improve computer capabilities by providing rich and feature full insights regarding whether the treatment applied to a
configurable application is statistically significant or not and to allow the server to
take appropriate actions, by selectively changing a feature of the configurable
application executing on the first system allows the application being executed to be
modified in "real time" without requiring a redeployment, etc. Furthermore, Claim 21
recites particular steps, as described above, that are performed to achieve the desired
outcome. Accordingly, under the August 4, 2025, Memorandum the USPTO guidance on § 101, Claim 1 is integrated into practical application.
Thus, Claim 21 is directed to patent eligible subject matter for reasons that were
provided in the response filed on August 18, 2025, in addition to the arguments and
amendments provided above. As such, Claim 21 is directed to patent eligible subject
matter. Claims 28 and 35 are also directed to patent eligible subject matter for similar
reasons as that of Claim 21. Dependent claims are also directed to patent eligible subject matter by virtue of their dependency in addition to their own patent eligible subject matter. As such, withdrawal of the rejection, under 35 USC §101, with respect to Claims 21-40 is respectfully solicited.
Examiner’s Response:
The Examiner respectfully disagrees. Please see response to arguments above with respect to claims 21, 28 and 35. The Examiner would also like to note that the current claim language does not include recitations of determining whether the treatment applied to a configurable application is “statistically significant or not”.
Therefore, for the reasons set forth above, the rejection made under 35 U.S.C. §101 with respect to claims 21-40 are proper and thus, maintained.
Conclusion
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/LANNY N UNG/Examiner, Art Unit 2197